Consultation outcome

Analysis: Proposed amendment to the assessment of Chinese and Japanese AS and A levels

Updated 13 July 2023

Summary

Ofqual consulted on a proposed amendment to the assessment requirements for AS and A level Chinese and Japanese qualifications being taught from autumn 2024. One of these requirements currently limits how many marks can be used for responses in English. Through its consultation, Ofqual sought views on whether, and if so how, it should amend this requirement.

Ofqual received 125 responses to the consultation.

The majority of respondents strongly agreed or agreed that Ofqual should amend its requirement:

• that no more than 10% of the total qualification marks may be used for responses in English for AS and A level Chinese and Japanese qualifications
• so that up to 40% of the total qualification marks may be used for responses in English for AS and A level qualifications in Chinese and Japanese

Ofqual’s proposal was in response to a separate consultation conducted by the Department for Education.

Background

Ofqual consulted on a proposed amendment to the assessment requirements for AS and A level Chinese and Japanese qualifications being taught from autumn 2024. The proposal was in response to a Department for Education (DfE) consultation on changes to its AS and A level subject content for the 2 logographic languages, Chinese and Japanese. One of DfE’s proposals was that the questions and responses for comprehension (listening and reading) tasks should be in English, rather than in the language of study. Ofqual does not have a requirement that specifies the language in which questions should be asked. It does currently have an assessment requirement that limits how many marks can be used for responses in English. To enable DfE’s proposed changes to its subject content to take effect, Ofqual would need to amend this requirement. Through its consultation, Ofqual sought views on whether, and if so how, it should amend this requirement for AS and A level qualifications in Chinese and Japanese.

The assessment requirements for AS and A level Chinese are published in Ofqual’s GCE Subject Level Conditions and Requirements for Modern Foreign Languages, and for AS and A level Japanese in Ofqual’s GCE Subject Level Conditions and Requirements for Modern Foreign Languages (listening, reading, writing). Ofqual currently requires that ‘no more than 10% of the total marks for the qualification may be used for responses in English’. In its consultation, Ofqual proposed amending this requirement for AS and A level qualifications in Chinese and Japanese so that up to 40% of the total qualification marks may be used for responses in English. This reflected DfE’s proposal that, for these 2 languages, responses to comprehension (listening and reading) tasks should be in English.

This document is the summary of responses to Ofqual’s consultation on a proposed amendment to the assessment of Chinese and Japanese AS and A levels. The consultation was open for responses between 26 April and 31 May 2023 and received 125 completed responses.

Approach to analysis

The consultation on the proposed amendment to the assessment requirements for AS and A level Chinese and Japanese qualifications was published on Ofqual’s website. It was available online and consisted of closed and open questions.

Four of the closed questions allowed respondents to indicate the extent to which they agreed or disagreed with the proposed amendment for each language. These questions used a 5-point scale (strongly agree, agree, neither agree nor disagree, disagree and strongly disagree). There were open questions, for each language, inviting comments on the proposal.

The Equality Impact Assessment and Regulatory Impact Assessment sections each included a closed question asking respondents if there were any impacts that Ofqual had not identified. They had to respond with ‘yes’ or ‘no’. These were followed by open questions where respondents could identify any impacts or mitigations of impacts on equalities or regulatory considerations as a result of the proposal.

Respondents could choose to respond to questions in the consultation and did not have to respond to them all. This analysis provides the number of responses received for each question. It also provides tables of the responses to the closed questions.

Respondents were asked to identify which group they belonged to, for example: teacher or student. The total numbers for each respondent group are set out in the tables in the section below, based on these descriptions. The tables use these unverified self-descriptions.

All responses to the open questions have been read in full. The key themes that emerged are presented in the detailed analysis.

A selection of respondents’ comments has been included in the report to illustrate the main themes identified. Some comments have been edited for clarity, brevity and to preserve anonymity but care has been taken not to change their meaning.

Some comments fell outside the scope of the consultation proposal. Ofqual has read the comments but has not included in the analysis matters that lie beyond the scope of this consultation. These comments were mainly focused on alternative or additional amendments that some respondents would like to see made to AS and A level qualifications in Chinese and Japanese. Common suggestions were to have different assessments for native and non-native speaking students, and to allow extended responses on literary works questions to be in English. Other suggestions included offering a choice of questions and tasks in exams, making literary texts more accessible, allowing dictionaries in the exam, and providing a vocabulary list for students and teachers. Where such comments related to the expectations set out in DfE’s subject content, these have been shared with DfE.

Who responded?

Ofqual received 125 responses to the consultation. The following tables provide a summary of respondents by type.

Official organisational responses	Number of respondents
Academy chain	6
Awarding body or exam board	1
Other representative or interest group	4
School or college	28
University or higher education institution	6
Total	45

Personal responses	Number of respondents
Awarding organisation employee	2
Consultant	4
Exams officer or manager	1
Other	9
Parent or carer	1
SLT (Senior leadership team)	3
Student	3
Teacher (responding in a personal capacity)	57
Total	80

This was a public consultation that asked for the views of those who wished to participate. Ofqual recognises that the responses are not necessarily representative of the general public or any specific group.

Detailed analysis

This section reports the views of those who responded to the consultation proposal.

Question 1

To what extent do you agree or disagree with the proposal to amend the requirement that no more than 10% of the total qualification marks may be used for responses in English for AS and A level Chinese qualifications?

Question 1 response	Count	Percentage
Strongly agree	74	60%
Agree	9	7%
Neither agree nor disagree	6	5%
Disagree	10	8%
Strongly disagree	24	20%

Total number of responses	Count
Question 1: response provided	123
Question 1: no response	2
Total	125

The majority of respondents, 67%, strongly agreed or agreed that Ofqual should amend the requirement that ‘no more than 10% of the total qualification marks may be used for responses in English’. There was a high level of support from schools and colleges, with 8 in 10 who responded to this question strongly agreeing or agreeing.

Currently, it is very hard for non-native speakers to compete on a level playing field with the number of native speakers taking the qualification. By increasing the percentage for responses in English, this imbalance will be addressed.

(School or college)

Twenty-eight per cent of respondents (34 respondents in total) disagreed or strongly disagreed with this part of the proposal. Of these 34 respondents, 27 went on to strongly agree or agree with the other part of the proposal in Question 2.

Question 2

To what extent do you agree or disagree with the proposal that up to 40% of the total qualification marks may be used for responses in English for AS and A level Chinese qualifications?

Question 2 response	Count	Percentage
Strongly agree	90	73%
Agree	17	14%
Neither agree nor disagree	4	3%
Disagree	4	3%
Strongly disagree	8	7%

Total number of responses	Count
Question 2: response provided	123
Question 2: no response	2
Total	125

The majority of respondents, 87%, strongly agreed or agreed that ‘up to 40% of the total qualification marks may be used for responses in English’. The strong support for this part of the proposal was widely evident across the respondent groups. All 6 academy chains and about 9 in 10 teachers, schools and colleges who responded to this question strongly agreed or agreed with this part of the proposal.

The reading and listening papers should reflect non-native speakers’ capacity to understand spoken and written communication. Given the current jump between GCSE and A Level, a greater proportion of questions that require a response in English to reading and listening passages would be appropriate.

(Teacher – responding in a personal capacity)

Many of the 27 respondents who strongly agreed or agreed with this part of the proposal but who disagreed or strongly disagreed with the first part, made detailed comments. These comments indicated their support for increasing the percentage of qualification marks that may be used for responses in English.

I think listening and reading comprehension questions must be tested in English given the fact that Chinese is character-based instead of alphabetical language, unless the writing skill is intentionally tested…

(Teacher – responding in a personal capacity)

Ten per cent of respondents disagreed or strongly disagreed that the percentage of marks that may be used for responses in English should be increased.

I think 10% for responses in English for AS and A level Chinese is a reasonable percentage of total qualification marks.

(Teacher – responding in a personal capacity)

Question 3

Do you have any comments about the proposal to amend the percentage of total qualification marks that may be used for responses in English for AS and A level Chinese qualifications?

There were 71 comments in response to this question. Many respondents commented that it was right to assess students’ comprehension skills through written English. They were concerned that currently students might understand what they are listening to and reading in an examination but not be able to demonstrate this unless they can write in Chinese to a certain standard.

This is an excellent idea, as the current exam arrangements fail to assess a candidate’s receptive skills, namely listening and reading. Reasons: we cannot tell whether a candidate’s inability to answer a question is due to their poor listening, or reading, or writing skill, or a mixture of all three.

(Teacher – responding in a personal capacity)

My students are finding writing characters… quite challenging. Responding to comprehension questions in characters is also demoralising because they could have got marks if they were allowed to write in English. If comprehension skills are tested, then writing characters is not necessary.

(School or college)

Testing students’ comprehension skills using English (in both questions and responses) is a much better fit-for-purpose approach to maximise the validity of the assessment. This is especially apparent considering the majority of prospective candidates are non-native Mandarin language users.

(School or college)

Many comments focused on the idea that Chinese has features which make it a particularly challenging language to study. They often made comparisons with other languages.

… Students of French, German, Spanish etc already know their alphabet from learning to read English and have only some hurdles relating to spelling and pronunciation to jump over. For ‘ab initio’ learners of Chinese… they must first learn new scripts before they can even start and this is not just another way of writing an alphabet as it is for say Arabic, Greek or Russian, but a whole different mindset…

Thus, if the students were able to show understanding of text without having to write in the target language they would be better able to show what they know…

(Teacher – responding in a personal capacity)

… When using the target language to test listening in Chinese, by requiring a learner to read the questions in Chinese and then write their responses in characters, it becomes a test of reading characters and writing characters from memory as well as listening.

One might understand the passage entirely but not remember a core character in the question and no answer would be possible. Or, one might know exactly the answer, even know how to speak it in Chinese, but if one does not remember how to write that particular character, there is no way of getting the marks. In a European language, a phonetic attempt is entirely possible and highly likely to be correct. Using English to showcase comprehension and proficiency in some skills is fair and proportionate.

(School or college)

Chinese… has comparatively much stronger opacity with its spoken language, and more significant cognitive load when facing reading the questions in written language and producing in written language simultaneously - without the relatively evident phonological cues in its written language (especially for novice second language learners), and without any cognates in its written language…

(University or higher education institution)

Some respondents commented that the demands of learning Chinese leads to a significant workload for students.

Chinese is considered one of the hardest languages to learn in the world… According to [research], for speaking and reading, the study of Chinese for English speakers requires nearly 4 times more time and effort than languages such as French, Spanish and Italian. Memorising Chinese characters is significantly more time-consuming than learning to speak and read Chinese…

(School or college)

There were comments that the current expectations of the qualifications lead to poor uptake at A level. Respondents also took the opportunity to express their opinion that these expectations are too demanding for students who are not native speakers of the language.

Currently A level Chinese/Japanese has become too hard for non-native students and we are worried that fewer and fewer students are taking the subjects in fear of their effort not getting rewarded fairly, when compared with other subjects.

(Awarding organisation employee)

It is important for the sustainability of the language that really high performing non-native speakers are afforded the same chance of gaining a top grade in Chinese and Japanese as other languages. Changing the qualification to allow non-native speakers to demonstrate their expertise in their own tongue will enable this to happen.

(School or college)

Of the 6 respondents who did not support either part of the proposal only 2 provided detailed comments. One of these respondents commented that the changes would be detrimental to students because they would not prepare students for real-life use of language. The other respondent said that due to the difficulty of the language the A level should be less focused on language acquisition.

…The rigid assumption that a ‘reading’ paper should only test ‘reading comprehension’ skills is absurd in real-life situations, and is therefore, as I call it, ‘artificial’… for a nationwide assessment where the differentiation between those who are more able and those less able is vital, changing the questions and responses into English - everybody’s first language - would defeat the purpose of differentiation. It makes it impossible to separate those who can demonstrate language skills when it comes to minute differences.

As long as the questions are set using words and vocabulary within the syllabus, students have a responsibility to learn them (and even if there are new words beyond a syllabus, a glossary can always be given)… Turning questions and responses away from the target language is, to me, a detrimental change. Instead, teachers and students should ensure they cover the syllabus in a robust manner, and the exam board should ensure questions are set at the right level…

(Teacher – responding in a personal capacity)

Chinese AS/A-level is not comparable to European language equivalents and we should stop pretending that they are. It makes much more sense for students to focus on the study of the country (including, but not limited to literature, for example) with some additional language basics rather than expecting and trying to get students to a decent level in the language.

(Other)

Question 4

To what extent do you agree or disagree with the proposal to amend the requirement that no more than 10% of the total qualification marks may be used for responses in English for AS and A level Japanese qualifications?

Question 4 response	Count	Percentage
Strongly agree	58	54%
Agree	9	8%
Neither agree nor disagree	16	15%
Disagree	11	10%
Strongly disagree	14	13%

Total number of responses	Count
Question 4: response provided	108
Question 4: no response	17
Total	125

The majority of respondents, 62%, strongly agreed or agreed that Ofqual should amend the requirement that ‘no more than 10% of the total qualification marks may be used for responses in English’. There was a high level of support from the schools and colleges who responded to this question with 7 in 10 strongly agreeing or agreeing with this part of the proposal.

I think the change will encourage more students to take A level Japanese.

(School or college)

Twenty-three per cent of respondents (25 respondents in total) disagreed or strongly disagreed with this part of the proposal. Of these 25 respondents, 19 went on to strongly agree or agree with the other part of the proposal in Question 5.

Question 5

To what extent do you agree or disagree with the proposal that up to 40% of the total qualification marks may be used for responses in English for AS and A level Japanese qualifications?

Question 5 response	Count	Percentage
Strongly agree	62	57%
Agree	18	17%
Neither agree nor disagree	17	16%
Disagree	4	4%
Strongly disagree	7	6%

Total number of responses	Count
Question 5: response provided	108
Question 5: no response	17
Total	125

The majority of respondents, 74%, strongly agreed or agreed that ‘up to 40% of the total qualification marks may be used for responses in English’. The support for this part of the proposal was widely evident across the respondent groups. The reasons given were very similar to the views expressed about the equivalent change for AS and A level qualifications in Chinese.

It is really important that students studying Japanese are not examined on Japanese writing skills, when the focus of testing at the time is listening or reading. This being the case, they need to be able to be asked and answer questions in English (or multiple choice) for these parts of the qualification.

(School or college)

Some of the 19 respondents who strongly agreed or agreed with this part of the proposal but had disagreed or strongly disagreed with the first part of the proposal added comments. These comments indicated their support for increasing the percentage of qualification marks that may be used for responses in English.

The questions and responses MUST be in English, unless writing skills are also intentionally being demonstrated.

(Teacher – responding in a personal capacity)

Question 6

Do you have any comments about the proposal to amend the percentage of total qualification marks that may be used for responses in English for AS and A level Japanese qualifications?

There were 36 comments in response to this question. Most of the comments reflected views that had been shared about the equivalent change for AS and A level qualifications in Chinese. A few respondents commented that it was right to assess students’ comprehension skills through written English. They were concerned that currently students might understand what they are listening to and reading in an examination but not be able to demonstrate this unless they can write in Japanese to a certain standard.

…Currently, most of these comprehension questions require answers in Japanese. However, it is unclear whether the candidates’ mistakes are due to problems of comprehension or problems with their writing skills when the candidates answer in the target language. Since the exam should be designed to measure language competence, questions that measure comprehension should be answered in English so that genuine comprehension can be measured.

Furthermore, we believe that increasing the percentage of responses in English would not be a disadvantage for either heritage language learners or those who learn Japanese as a foreign language. This is because heritage language learners are not necessarily good at answering questions in the target language. Some are good at speaking, but poor at writing in the target language.

For language learners, being able to output in the target language is not the only linguistic competence. It is also important to understand the target language and its culture, and to be able to play a role in communicating this knowledge to others using the learner’s own language. The increase of the percentage of responses in English would not spoil the candidates, but rather would help them pursue a higher quality of language learning…

(Representative or interest group)

Some comments focused on the idea that Japanese has features which make it a particularly challenging language to study. They tended to make comparisons with other modern foreign languages, including Chinese.

…In Chinese each ‘character’ has one pronunciation, in Japanese a single ‘character’ can have up to 9 pronunciations based on its function in the sentence! All of this must be learnt while conforming to a Eurocentric curriculum load - conservative estimates suggest at least 25% more time is required for even the simplest activity if reading or writing are involved. Thus, if the students were able to show understanding of text without having to write in the target language they would be better able to show what they know.

(Teacher - responding in a personal capacity)

Some respondents who supported the proposal commented that the current requirement makes the qualification unfairly demanding. Some expressed concern that the current expectations are too demanding for students who are not native speakers of this language. In turn, they commented that this is impacting on the numbers of non-native speaking students choosing to study Japanese AS and A level.

…Making Japanese and Chinese A levels more accessible to non-native speakers (especially to those in state schools, with less access to resources and teaching expertise) is a crucial step, and one that those of us affiliated with UK East Asian Studies departments have been advocating for years.

(Other)

The latest Japanese A level specification… presents a much, much more challenging set of requirements - both linguistically and cognitively… Additionally, it seems that a considerable proportion of candidates are highly likely to be native speakers of Japanese. The combination of these factors is putting “normal” non-native learners of Japanese at a disadvantage and this, in turn, is proving to be a disincentive to GCSE students considering Japanese A level…

(Teacher – responding in a personal capacity)

It would make the qualification far more realistic for non-native speakers of Japanese and make the A level more of a level playing field for the non-native speakers…

(Teacher – responding in a personal capacity)

Six respondents did not support either part of the proposal. One respondent suggested that Japanese A level should maintain its high level of demand and expect wide use of the target language in the examination. Another repeated comments they had made in relation to Chinese that due to the difficulty of the language the A level should be less focused on language acquisition.

I teach Japanese to private candidates and I am also fluent. I feel that at GCSE then yes, a lower Japanese writing requirement is fine, but at A level there should be a high level of proficiency, and responses should be recorded in Japanese, with the exception being the Japanese to English translation segment.

(Teacher – responding in a personal capacity)

Japanese AS/A level is not comparable to European language equivalents and we should stop pretending that they are. It makes much more sense for students to focus on the study of the country (including, but not limited to literature, for example) with some additional language basics rather than expecting and trying to get students to a decent level in the language. I would like to see as much as 80% of the assessment be done in English.

(Other)

Equality impact

As a public body, Ofqual is subject to the public sector equality duty. The consultation considered whether the proposal might impact (positively or negatively) on students who share protected characteristics.

Question 7

Are there any potential equality impacts that Ofqual has not identified? [Yes or no]

Question 7 response	Count	Percentage
Yes	21	17%
No	104	83%

Total number of responses	Count
Question 7: response provided	125
Question 7: no response	0
Total	125

All respondents answered this question with the majority (83%) answering ‘no’.

If yes, what are they?

There were 21 comments in response to this question. Most of these comments either fell outside the scope of the consultation or related to the proposal more generally and, as such, have been addressed above. A couple of respondents suggested that non-native speakers should find the qualifications more accessible if the amendment is made.

This consultation is a step towards reducing the existing discrimination against non-native candidates in an examination where the VAST majority of candidates are Asian native speakers.

(Other)

Three comments related to students with English as an additional language (EAL) and native speakers of Chinese and Japanese. These respondents indicated the amendment could increase the challenge for some students whose first language is not English but noted that the impact of this could be variable.

Candidates’ backgrounds are different. Increasing the content of answering in English will help non-native students but will disadvantage native students who also take this qualification.

(Teacher – responding in a personal capacity)

… There are various patterns among candidates, and whether their first language is English or Japanese, even among heritage language learners the level of proficiency in each language varies from person to person.

There are some heritage language learners who are poor at answering in Japanese, and therefore, increasing the percentage of responses in English would not be a disadvantage for such heritage language learners. Again, those learners who are not good at English should be taken into consideration.

(Teacher – responding in a personal capacity)

Two comments were about protected characteristics and referred to students with dyslexia and students with specific learning difficulties. These comments did not specify further potential impacts arising from the proposal but one said the amendment would go some way to addressing existing difficulties.

I think that the current arrangements present (a) barriers to student access to the tasks in the first place (use of Chinese/Japanese where this is not necessary to the declared objectives of the tasks) and (b) flaws/confusions in assessment design that are likely to affect, disproportionately, students with, for example, specific learning difficulties (notably requiring answers written in Chinese/Japanese where writing is not the sole or main outcome under assessment)… The proposed changes will mitigate those, to some extent, but not fully.

(University or higher education institution)

Question 8

Do you have any suggestions for how any potential negative impacts on particular groups of students could be mitigated?

Most of the 34 comments in response to this question fell outside the scope of the consultation proposal. Many of these comments were focused on alternative or additional amendments to the qualifications as noted earlier in this document.

Five respondents offered suggestions to mitigate potential impacts for the particular groups of students identified above in question 7. The 2 respondents who commented on potential impacts for students with dyslexia and specific learning difficulties made general suggestions about ways to potentially improve the assessment design in the future.

Limit question type. Ensure the wording of Mark Scheme is comprehensive, and the answer key words are not too specific.

(Teacher – responding in a personal capacity)

A couple of respondents suggested that native speakers of Chinese and Japanese should have the option to respond in their own language, rather than in English. Another respondent commented on difficulties for students with English as an additional language. They reiterated the importance of not judging the spelling, punctuation and grammar of English written responses where this is not part of the assessment expectations.

Non-native speakers of Japanese who are stronger in Japanese than English should be allowed to use Japanese in their exam. (In the unlikely event that recently arrived EAL students to the UK from non-English speaking countries, where they had studied Japanese as a foreign language.)

(Awarding organisation employee)

…Disadvantaging those candidates whose first language is not English should be avoided. An example of a solution to this potential issue would be not deducting points for English grammatical and spelling mistakes. Since the candidates’ understanding of the target language should be evaluated, rather than their English skills, it is necessary to be thorough so that points are not deducted for any reason other than as a result of evaluating language competence…

(Teacher – responding in a personal capacity)

Regulatory impact

Question 9

Are there any potential costs or burdens that Ofqual has not identified?

Question 9 response	Count	Percentage
Yes	13	10%
No	112	90%

Total number of responses	Count
Question 9: response provided	125
Question 9: no response	0
Total	125

All respondents answered this question. Ten per cent of respondents stated that there were potential costs or burdens that Ofqual had not identified.

If yes, what are they?

Ofqual received 12 comments in response to this question, including 11 from respondents who answered ‘yes’ and one from a respondent who answered ‘no’. None of the comments identified potential costs or burdens in relation to Ofqual’s proposal that it had not already identified. One respondent stated that there would not be any other costs or burdens.

I can see none; no retraining of teachers would be necessary; one set of specimen papers would be all that is necessary for teachers to understand the changes.

(Teacher - responding in a personal capacity)

Other comments were out of scope and were mainly focused on alternative or additional amendments to the qualifications as noted earlier in this document.

Question 10

Are there any steps Ofqual could take to reduce the costs or burdens of the proposal?

Ofqual received 16 comments in response to this question. Two respondents suggested no steps needed to be taken because there would not be additional costs as the teaching content would not be changed, or that there would only be increased cost and burden in the short term.

A few respondents used their comments to suggest how costs or burdens might be mitigated.

The government are keen to support schools to offer modern languages. Would there be any funding available from that for this area? In the global market, would businesses consider investing in the language skills of the next generation?

(Teacher – responding in a personal capacity)

As there’s more and more need of teaching Chinese in UK schools, there will be more need of students taking A level Chinese. The proposal will eventually generate income to cover the initial cost.

(School or college)

Two respondents used their comments to suggest ways of making sure stakeholders were clear on the amendment if it happened.

Create short video clips to highlight the changes and then disseminate via Click view or YouTube so that they can be accessed by teachers, students and parents at any time and any place.

(Teacher – responding in a personal capacity)

Other comments were unrelated to the proposal and were further suggestions for alternative or additional amendments to the qualifications.

Annex A: List of organisational respondents

When completing the consultation questionnaire, respondents were asked to indicate whether they were responding as an individual or on behalf of an organisation. These are the organisations that submitted a non-confidential response:

• Bohunt School and Sixth Form
• Brighton College
• British Association for Chinese Studies
• City of London School for Girls
• Downe House School
• Durham University
• Finham Park School
• Gosforth Academy
• Gosforth Group
• Harris Academy South Norwood
• Harris Federation, Swire Chinese Language Foundation
• King’s College School Wimbledon
• King Edward VI Aston School, Birmingham
• Lancaster University, Department of Languages and Cultures
• Manchester Grammar School
• Melbourn Village College
• Newcastle University
• Norwich School
• Oundle School
• Oxford High School GDST
• Pearson
• Prior Park College
• Queen Mary’s High School
• St Gabriel’s School
• St Mary’s School, Calne
• Stowe School
• The Birmingham Chinese School
• The Elms Academy
• The Godolphin and Latymer School
• The Japan Foundation, London
• University College London
• University of Oxford
• University of Sheffield